The UK and EU are pushing for AI leadership, but with critical differences in approach. What can we learn, and how might things change?

After the EU's Artificial Intelligence Act was adopted in May, and comes into force over the next two years, , the UK has so far held firm in adopting an alternative ‘pro-innovation’ approach to regulating AI, with a less comprehensive AI Bill going through at the moment which focuses on setting up an AI Authority and aligning to international standards.

In its 2023 AI White Paper, the UK government proposed a sector-focused, principles-based regime to regulate AI, believing that “rigid and onerous legislative requirements on businesses could hold back AI innovation and reduce our ability to respond quickly … to future technological advances”.

On the face of it, this ‘hands off’ stance looks like a viable way to continue. For a start, the UK packs a punch in global AI rankings – placed 4th internationally in the Global AI Index, thanks to a consistent high caliber pool of tech talent. It has delegated responsibility to existing regulators to clarify which current legislation applies to AI, fearful that legislative red tape will dampen innovation and competitiveness in a field that’s growing, with a bright future. Global competitors are circling looking for investment, and the government has complemented this with cash to fuel development, recently investing £100 million in AI regulation research and development.

But it seems likely the UK’s approach will change, and more quickly than we might think.

Alarm bells

There is a growing public concern for data privacy, accompanied by evolving regulations and an increase in consumer awareness, which necessitates a proactive and structured approach.. Thoughtworks’ own research highlights this; whilst 83% of consumers agree that businesses using AI ethically can drive innovation and enhance customer experiences, nearly two-thirds worry about a lack of human oversight in AI interactions. And 93% believe businesses that neglect responsible and ethical AI practices risk detrimental impacts.

Alongside this, concerns around the influence of a small number of very powerful technology companies to shape the AI future are triggering competitive alarm bells.

So what can we learn from the UK and EU’s stances on AI, as global markets move towards more developed regulatory frameworks? There are strengths but also significant weaknesses in the current UK approach to AI regulation – here’s some key areas that require focus.

Sustain a growing AI skills base

Collaboration with EU regulators can augment the UK’s existing AI expertise and talent pool, ensuring consistent enforcement across borders, and prevent duplication of regulatory efforts.

Whilst it was great to see specific AI funding in the UK’s Spring Budget, there are areas which need more funding to keep pace with other countries. The UK has such a high caliber of AI expertise which is one reason it's currently ranked so highly on the Global AI Index. To maintain this pace, the UK’s Spring Budget needed to have included funding for Data and AI education, for example.

Focus on building trustworthy and responsible AI

The EU AI Act places human oversight, explainability, and data governance center stage. This is critical, both in terms of mitigating bias and discrimination in AI outputs and decision making, and also as a cornerstone of public trust. The Global AI Index shows the UK lagging when it comes to its AI ‘operating environment’ – including the public's opinion on artificial intelligence. There is much work to be done to educate the public on AI and its usage, and further regulation can help build public trust.

Transparency and ethics in AI also matter hugely. People should be aware when they’re interacting with artificial, not human, intelligence, for example. Abuses like manipulating user preferences or utilizing AI for harmful purposes like social mobilization or creating illegal content must be actively discouraged.

Educate around requirements for AI risk mitigation

A strong example here is the way companies frequently fall into a data protection blind spot by mistakenly assuming ‘personal data’ only applies to their customers – leaving employee data dangerously exposed to damaging data breaches. Important employee data, from home addresses, bank account details, IP addresses to even more sensitive details like political opinions or genetic data could potentially be accessed by unauthorized bad actors.

Accelerating too quickly or lagging too far behind?

This discussion underscores the delicate balance between promoting growth and innovation in the AI sector and managing institutional and individual risks, rights, and freedoms. Accelerating too quickly may lead to poorly conceived regulations, whereas moving too slowly could critically undermine the UK's position as a leader in AI. Interestingly, UK companies stand to benefit from aligning with the EU's Artificial Intelligence Act, as it allows them to adapt to comprehensive standards without feeling rushed by looming deadlines and fines.

The UK's cautious stance against overregulation during the nascent stages of AI development is a strategic advantage. It ensures that innovation is not prematurely constricted, fostering an environment where AI can mature at a natural pace. However, when the time comes to adopt more stringent regulations, the UK would do well to model them closely on the EU's framework. A divergent approach between the two could lead to conflicts that would serve neither businesses or consumers well. Ultimately, deeper regulatory changes in the UK seem inevitable and necessary, aimed at harmonizing with broader standards while safeguarding the nation's competitive edge in AI.

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